MSC - Marine Stewardship Council Consultation … - Marine Stewardship Council Consultation Document: Scope of Certification Consultation Dates: 25th June – 10th August, 2012 MSC

MSC - Marine Stewardship Council

Consultation Document: Scope of Certification

Consultation Dates: 25th June – 10

th August, 2012

MSC Contact: Ben Snowden

FOR CONSULTATION

Introduction:

Under the current Chain of Custody (CoC) requirements, the certifier determines the scope of certification for each client – this consists of information on the fisheries sourced from, species handled, and very detailed data about the product and storage forms. This data is entered and maintained by certifiers in the MSC’s eCert database.

As the MSC programme has grown over the last few years, managing scope of certification has become an increasing burden for certifiers and certificate holders, particularly those that source large varieties of MSC species or have frequent changes in product form and presentation. Entering data into the eCert database is time-intensive and many certifiers charge a fee to clients for each scope extension. The requirement to have all scope extensions approved by the certifier and managed through eCert creates a cost (of up to £300 per extension in some cases) and a delay to companies, and serves as a disincentive to increase the amount of MSC products sourced.

As a result, many certificate holders request a broader scope of certification than they actually require, in order to avoid scope extensions if they want to add additional species, fisheries, or products in the future. This in turn has compromised the integrity of the data that feeds the MSC’s ‘Find a Supplier’ tool and negatively impacts the main objective of capturing product-level information, which was to provide value for certificate holders through connecting buyers and suppliers of certified seafood.

Purpose:

This project aims to review the concept of ‘scope of certification’ as it relates to MSC’s CoC certification requirements, and to explore options for reducing the administrative burden and cost of managing scope information. This project has arisen largely due to feedback from certificate holders and certifiers indicating that current requirements for scope of certification are impractical and administratively burdensome, without adding clear value to the programme.

This consultation is designed to solicit stakeholder input on two potential options for managing scope of certification in the future. All stakeholders are invited to provide feedback on how they currently use scope information and the MSC’s ‘Find a Supplier’ site, and to highlight particular benefits or considerations related to the options laid out below.

Recommendations:

In response to growing stakeholder concerns about scope and in order to help enable future growth of the MSC programme, the MSC is currently evaluating two options for managing scope of certification in the future. These options are summarised below, with more detailed descriptions in the background paper.

Option 1: Maintain the existing definition of scope and the existing process for scope changes, but allow all information other than activity to be updated on a minimum 6 month basis, rather than immediately

This option would maintain the current definition of ‘scope of certification’ but change the requirements around time limits for updating certain elements of this information. Any changes to activities would still require the certifier to be notified before changes can take place. However, companies would only need to ensure all other scope information (fisheries, species, product form, presentation, etc.) is updated on a minimum every 6 month basis. The accuracy of scope data would continue to be verified by certifiers during regular surveillance and recertification audits.

http://www.msc.org/

FOR CONSULTATION: 25th June – 10th August 2012

Consultation Document: Scope of certification 2

Option 2: Revise the concept of ‘scope’ to include only activities and ecolabel use; allow companies to manage species, supplier, and product information directly through a new Find a Supplier web portal

This option would revise the existing definition of scope so that once certified, a company is able to handle all MSC certified products and species. Each company would still have a ‘scope of certification’ but this would be redefined to only include information on activities (i.e. processing) and whether the company uses the MSC ecolabel (and thus is required to have a valid ecolabel license agreement). This information would be managed by certifiers according to the current process and maintained in the eCert database.

In parallel, a new ‘Find a Supplier’ interface would be developed that will allow certificate holders to maintain their own information related to the fisheries they source from, which species they handle, product form and presentation.1 This ‘Find a Supplier’ site could add greater commercial value through incorporating elements such as brand names and product images for supplier searches, and initial consultation suggests many companies would be willing to be responsible for maintaining this information. To help ensure accuracy and value of the ‘Find a Supplier’ site, companies would be required to keep this information up-to-date within three months, and the accuracy would be checked by certifiers during onsite audits. It is proposed that a minor conformity would be raised by certifiers if the information on a client’s ‘Find a Supplier’ entry is not kept up-to-date.

Considerations:

These options aim to preserve important information currently captured within scope of certification, to improve the accuracy and usability of this data, and to manage scope information in a way that encourages, rather than discourages, the sourcing of more MSC certified products in the future.

Considering the feedback and research carried out to date, the MSC executive favours Option 2 as described above. As the number of certified fisheries and CoC holders continues to grow, managing scope under the existing system will require increasing amounts of time and effort and scope will continue to act as a disincentive for companies to source additional MSC products. Option 2 will ensure certifiers continue to manage activity data for each company and provide some oversight to ensure additional product and species data is updated by the company. This will help to enable future growth of the CoC programme and provide greater commercial value to existing certificate holders.

However, Option 2 represents a significant shift from the current scope of certification model. Careful consideration of realistic technology options and how new solutions will interface with existing databases and websites will be required. In addition, on-going feedback from the consultation process will be critical to ensure the final solution maximises value for stakeholders and minimizes costs, while preserving the integrity of the CoC programme.

Specific benefits and risks associated with each option are outlined in greater detail in the background paper for this consultation.

1 Initial conversations with developers suggests this type of platform could be built in less than one month, although the need to link data

with existing MSC databases might extend this timeframe slightly



BACKGROUND PAPER:

A. Introduction:

Over the last several years, certificate holders, certifiers, and other stakeholders have raised increasing concerns about the time and cost required to maintain scope information. As the MSC continues to grow, and the number of certified fisheries and supply chains increases, managing scope of certification is likely to become an even greater challenge in the future.

In the current Certification Requirements, scope of certification is defined as “specific activities and products for which certification is sought or has been granted.” Under section 17.2, the scope of a CoC certification is determined by the certifier based on the following:

The fishery(ies) (MSC-certified or under-MSC-assessment) that product is to be sourced from

The species that are to be sourced / sold

The activities to be undertaken, i.e. the product form; type of storage and presentation ( see Table BB2 in Annex A)

The options for scope information are set out in the table below. This information needs to be determined for each species the company handles; for example, if the company processes both Mackerel and Haddock, they would need to identify all activities, product forms, storage, and presentation for both Mackerel and Haddock, and this data would need to be entered as separate line items into the eCert database.

Table B1 : List of scope options



When a company receives CoC certification, the certifier must enter their full scope information into the MSC database (eCert), which for some companies can include dozens of different species and dozens of product forms for each species. The certifier is responsible for keeping this information up-to-date within the eCert website and making sure any changes to scope are reflected within eCert.

Sample scope data as captured within the MSC’s eCert database:2

Currently, when companies want to change their scope of certification (for example, to source a new species of MSC certified seafood or produce new certified products), they must apply to their certifier for a scope extension before the change has taken place.3 Certifiers are required to review all scope extension requests and determine if the certificate holder’s systems are suitable for the proposed new scope of operations, whether conformity with the MSC standards will be maintained, and whether an onsite audit is required. The certifier must also then record the rationale for their decision, and must update the scope changes (if applicable) in the MSC’s eCert database within 10 days (CR 17.7.5).

Scope of certification was initially developed to serve two separate objectives:

1. Information on activities and species was intended to assist certifiers in the certification and audit process through providing information on the company’s activities, as well as highlighting risk factors such as the potential of product substitution

2. Information on product form, storage, and presentation, was primarily intended as a marketing benefit for certificate holders, through facilitating business transactions via the MSC’s ‘Find a Supplier’ tool (which is fed by scope information in the MSC’s eCert database

When the MSC programme had first been launched and there were a limited number of fisheries and CoC certified companies, this system worked fairly well for managing data on the companies and connecting buyers and suppliers of certified products.

However, there is evidence to suggest that as the MSC programme has expanded in size and complexity, scope information has become less effective at providing marketing benefits through use of the Find a Supplier tool. Companies commonly request broader ranges of products or species to be added to their scope than they actually handle, in order to avoid being charged by certifiers at a later date. As a result, the Find a Supplier tool (which draws directly from the eCert database) is unable to provide accurate product information.

This has substantially compromised the accuracy and value of the Find a Supplier tool, and leads many MSC outreach staff to rely on other methods (such as their own personal knowledge) to connect suppliers and buyers of certified products.

Suppliers: Although supplier lists are not technically included in the definition of scope of certification as defined in section 17.2 of the Certification Requirements, each certificate holder must provide their certifier with a full list of the company’s suppliers of certified products. This information is contained on a separate tab within the eCert database. Any changes to suppliers must be communicated to the certifier within ten days of the company receiving a delivery from the new supplier.4 Feedback from companies suggests that this requirement can discourage sourcing MSC products from new suppliers, particularly for companies such as fresh fish mongers or traders who

2 Refer to Annex B for a larger version of this screenshot

3 As per CR v1.2 section BD1.2.2

4 As per CR v1.2 section BD1.2.3.1



may buy from a wide variety of suppliers. Therefore, possible changes to managing suppliers has been included in the development of policy options #1 and 2.

B. Summary of stakeholder feedback to date:

To better understand concerns about the existing scope of certification requirements, initial consultation was conducted with certifiers, certificate holders, MSC Outreach staff, and other relevant MSC representatives on the following topics:

1) Current uses of scope information

2) Challenges with the existing scope requirements

3) Usefulness of the current Find a Supplier tool

A summary of feedback in each of these areas is set out below:

1) Current uses of Scope information

Annex C includes a full list of current users initially identified, with a summary of feedback gathered up to the time of this consultation document being released. Below is a summary of annex C which covers the main stakeholders that currently use scope information:

Stakeholder Key Uses of Scope Information and the Find a Supplier Site

Certificate Holders

Access scope data through the Supplier Directory to:

Find potential business partners

Find new suppliers and sources of MSC species, products and forms

To check the validity of suppliers’ CoC certificates

Certifiers (CABs)

Scope data used to help prepare for audits – determine processes and products to be covered in the audit and gauge risk levels

Understand client’s needs and activities

Update supplier lists in eCert

To confirm species and product forms

For checking validity of logo licenses of certificate holders

MSC Ecolabel Licensing team

Use scope data through eCert for ecolabel product approval: to check that products sent to MSCI are within the company’s scope, and are eligible to carry the MSC logo and claim

MSC Outreach teams

Determine needs of potential/ current certificate holders

Enable linking of partners and certificate holders/ suppliers

Ascertaining impacts of suspensions, withdrawals, and gaps in supply chains

2) Challenges with the existing scope requirements

Comments from CoC certificate holders and certifiers indicate that there is a lack of understanding about why some information (such as detailed product data) needs to be managed by the certifier, that the current process is labor intensive for both companies and certifiers, and that for many companies, existing scope requirements serve as a deterrent to sourcing new MSC products.

Concerns with the existing scope of certification process can be grouped into the following high-level areas:

Administrative effort: Entering initial scope information into the MSC database and processing scope extensions can be a significant administrative burden for both companies and certifiers.



This is particularly true for companies that source a wide variety of certified products or have frequent changes to their products or suppliers (for example, traders or fishmongers). In some cases, certifiers need to enter as many as 60 species into the eCert database to set up the initial scope, with upwards of a dozen different product forms/ presentation types for each species. In the MSC eCert database, entering this data is a very manual process and requires significant time on behalf of certifiers (or their administrative staff). The MSC has been alerted of cases where certifiers can spend half a day of time entering the scope for one complex client, or cases where certificate holders had to wait several months before their request for scope extension was processed.

Costs of scope extensions: Since changes to scope must be done through a certifier, certificate holders often have to pay the additional costs to add new MSC products or species. Each certifier sets their own rates for scope extensions, which can vary based on the type of client, the contract details, and the complexity of the extension request. However, general feedback from the questionnaire sent to certifiers in May 2012 reveals that most certifiers do charge for scope extensions, and the fees can around £80 on the low end to upwards of £300.

Unclear rationale: There is some lack of understanding amongst certificate holders and certifiers about the underlying rationale behind scope of certification and how this data is used, both in concept and in practice. For example, many certificate holders do not understand the relationship between product-level data in scope and the existence of the Find a Supplier tool, which was designed originally to add value to certificate holders. Without this knowledge, certificate holders don’t understand why they must provide such detailed information to certifiers on product form and presentation, and view this as an unnecessary administrative burden.

Inaccurate scope data: The MSC is aware that under the current system for scope, companies often request a greater scope of certification than they actually require, in order to give them more flexibility in sourcing and to avoid the administrative and cost burden of future scope extensions. This in turn has led to inaccurate information on certificates and compromises the usefulness and accuracy of the ‘Find a Supplier’ tool, which is linked to scope data in eCert.

Furthermore, conversations with certificate holders and certifiers suggest that scope categories do not always add additional traceability assurance back to fishery-level data, because many companies don’t know the source fishery for their MSC products. Under the CoC standard, the MSC does not require suppliers to name the source fishery on invoices, delivery notes or packaging5. Certificate holders therefore often ask the certifier to add all certified fisheries of a species to their scope.

In addition, certain elements of scope, such as activities and presentation form, are not fully defined and often inconsistently understood by certifiers. This leads to further inaccuracies of the data in the Find a Supplier tool and creates confusion amongst certificate holders.

3) Usefulness of the existing Find a Supplier tool

Stakeholder feedback indicates that most certifiers are reasonably satisfied with the Find a Supplier tool as it stands, although most don’t use the tool on a frequent basis. However, opinions from both certificate holders and MSC outreach staff indicate that the tool needs substantial improvement in order to deliver on its original aim of adding value for certificate holders. Many MSC Outreach staff note the Find a Supplier site has the potential to be very useful, but doesn’t fulfil its potential due to inaccurate data and limited search functionality.

Referring potential clients to the website and having them locate companies that don’t actually supply the listed products can create frustration and can undermine the credibility of the MSC programme. Thus, rather than referring clients to this tool, some MSC outreach staff will send potential clients Excel spreadsheets with relevant supplier data, or will rely on internally maintained, region-specific lists of suppliers as a primary record instead.

5 The CoC standard version 3 requires that product or batch can be traced to a certified source, not a certified fishery



Interviews with nearly a dozen certificate holders suggested that these companies very rarely use the current Find a Supplier tool, and do not derive significant commercial value from it. However, companies generally supported the idea of having a more detailed, accurate, and searchable version of this tool – and felt it would be no problem for them to maintain product and brand-level information directly.

Additional data on how the Find a Supplier tool is currently used will be collected over June- July 2012 using an analytical survey tool incorporated into the website. The results of this analysis – including who is accessing the site, what they are searching for, and feedback on the site’s effectiveness – will also help to shape the development of new solution options.

C. Risks and benefits of potential policy options:

As the number of certified fisheries and products continues to increase, managing scope of certification will likely become more complex in the future, resulting in continued additional costs and administrative burdens for certificate holders. Although one of the original intents of the scope requirement was to help grow the market through connecting buyers and suppliers of certified products, it could begin to have the opposite effect. If scope changes continue to be costly and time intensive, companies may hesitate to add new MSC products and will find their flexibility in sourcing limited, particularly if there is variable supply of MSC products (as is often the case for fresh fish counters that source locally).

Concerns over scope of certification should also be viewed in the broader context of stakeholder frustration about the overall cost and complexity of CoC certification. Although scope requirements alone are unlikely to cause companies to withdraw from the MSC programme, when added together with audit costs and administrative requirements, there is a real possibility of certificate holders opting out of the programme.

Option 1: Maintain existing definition of scope and the existing process for scope changes, but allow all information other than activity to be updated on a minimum 6 month basis, rather than immediately

Description: Under this option, the existing definition of ‘scope of certification’ and all data included would remain the same, but the time limits would be changed for updating certain elements of scope data. Any changes to activities would still require the certifier to be notified before changes can take place. However, companies would only need to ensure all other scope information (fisheries, species, product form, presentation, etc.) is updated on a minimum every 6 month basis. Changes to this information would still need to be communicated to the certifier (as per the existing process) and the accuracy of scope data would continue to be verified by certifiers during regular surveillance and recertification audits. All scope information would still be maintained in the eCert database, and the Find a Supplier tool would continue to be fed by this data.

Supplier lists would also continue to be managed by the certifier, with data maintained on eCert; however, certificate holders would only need to update their supplier list on a minimum 6 month basis (rather than within 10 days of using a new supplier, which is the current requirement).

Option 1: Maintain existing definition of scope and the existing process for scope changes, but allow all

information other than activity to be updated on a minimum 6 month basis, rather than immediately

Benefits Risks

1. No direct financial costs for new systems or technology

2. No need to train certifiers and Outreach staff on new requirements

3. Addresses pressing concerns from certificate

1. Could negatively impact the accuracy of data in the Find a Supplier site (although it is believed this data is already inaccurate to some degree)

2. Certifiers will still be required to manage all scope data through eCert (time-intensive process, may still require



Option 1: Maintain existing definition of scope and the existing process for scope changes, but allow all

information other than activity to be updated on a minimum 6 month basis, rather than immediately

Benefits Risks

holders and certifiers about managing scope extensions

4. Certifier maintains control over all scope information

5. Technology systems and basic procedure remains the same (minimal need for additional training/ communication of changes)

6. May be a very good interim solution while further analysis is conducted on options for managing scope

clients to pay for scope extensions)

3. Doesn’t address certificate holder questions about the purpose of having all product data managed by the certifier

4. May increase complexity of scope-related requirements (i.e. different requirements for activities & species vs. all other scope data)

5. Potentially more challenging for certifiers to determine compliance through audits because scope information isn’t kept up-to-date in eCert (MSC will need to provide more guidance about how to verify scope data is correct during onsite audits)

6. Possible concern that MSC is perceived as not going far enough to respond to stakeholder concerns about scope

Option 2: Revise the concept of ‘scope’ to include only activities and logo license use; allow companies to manage species, supplier, and product information directly through a new Find a Supplier portal

Description: Revise the existing definition of scope to include information on activities and whether the company uses the MSC ecolabel. Including information on logo license use is in response to certifier feedback indicating that it would be very helpful before an audit to know whether a company is required to have a valid ecolabel license agreement, which would be verified during the audit.

This revised scope information would be managed by certifiers according to the current process and maintained in the eCert database. A new Find a Supplier interface would be developed that will allow certificate holders to enter and maintain their own information related to:

Fisheries sourced from (if known)

Certified species handled

Product form, storage, and presentation

This data would be searchable through the Find a Supplier site, and could also include optional data such as brand names and product images – thereby making the site more commercially useful as a mechanism for connecting buyers and suppliers of certified products. Initial consultation with certificate holders suggests many companies would be willing to be responsible for maintaining this information. Companies could be required to keep this information up-to-date within three months, and the accuracy could be verified by a certifier during an onsite audit. Before conducting an onsite audit, the certifier would be able to access the company’s profile from the Find a Supplier site and could download all relevant information, which would be verified during the onsite audit. It is proposed that a minor conformity would be raised by certifiers if the information on a client’s ‘Find a Supplier’ entry is not kept up-to-date.

Supplier lists would also be managed directly by the certificate holder using this web interface, which would eliminate the need for any new suppliers to be communicated to the certifier and updated in the eCert database. This supplier information would remain confidential on the site and would be visible only to the company, their certifier, ASI, and the MSC.



Option 2: Revise the concept of ‘scope’ to include only activities and logo license use; allow companies to manage species, supplier, and product information directly through a new Find a Supplier portal

Benefits Risks

1. Encourages greater uptake of the MSC programme through removing barriers that prevent companies from sourcing new MSC products, developing new products, or buying from new fisheries

2. Creates greater value for MSC certificate holders through creating a more usable, versatile, and accurate Find a Supplier site

3. Creates commercial incentives for companies to maintain their own product-level information in order to get maximum benefit from the supplier site

4. Addresses pressing concerns from certificate holders and certifiers about managing scope extensions

5. Adds additional information about logo license use into scope definition – this has been requested by certifiers to help

6. Certifier maintains control over the elements of scope that are most critical for determining risk levels (i.e. activities and species)

1. Certificate holders are required to take on more responsibility

2. Certifiers have reduced control over exactly which products are handled by each company (although possible that information in the new Find a Supplier site could be more accurate than existing scope data in eCert)

3. Companies may not keep information perfectly updated on Find a Supplier site, and this will continue to be checked at a minimum during certifier audits

4. The MSC may need to provide additional guidance to certifiers on how to verify information in the Find a Supplier website during onsite audits


ANNEX A: Description of Activities for Scope of Certification

This table is extracted from the MSC’s Certification Requirements, v1.2

Table B2: Activity Scope Definitions

Activity Definition

1 Trading fish (buying/selling)

This will likely be in nearly every company's scope, with the exception of contract processors that do not take ownership of the product. In most instances, an additional activity will also be selected for this client, unless they are solely a 'trader'. If they will take possession, they will also need to have 'storage', 'wholesale' or 'distribution' selected.

2 Transportation Transportation companies are not required to be certified for CoC, unless they also take ownership. In some cases, however, using a transport company could increase the risk to such a level that you would require your client to ask a company to be certified - for example a vessel involved in transhipping.

3 Storage This refers to product being held in a storage area by a company before processing/distributing/selling it and after processing it. This will also likely be included in many of the clients' scopes as they will be storing fish before processing/distributing/selling it and after processing it.

4 Distribution Distribution shall be used for companies that receive sealed containers, pallets, etc, that may or may not be broken down into smaller sealed units, and DELIVER them to customers or other members of their group. I.e. they take possession, but not ownership.

5 Wholesale

Wholesale shall be used for companies that receive sealed containers, pallets, etc, that may or may not be broken down into smaller sealed units, and SELL them to customers or other members of their group. I.e. they take ownership and possession.

6 Harvest This shall be used when the fishing vessels are being certified. If they are processing on board, processing should also be recorded.

7 Packing or repacking

This shall be used when the packaging is changed but the product remains the same. It is assumed that companies processing will also be packing, so it is not necessary to select packing as well as processing. If there is a company that is receiving product from a processing company for the sole reason of packing it into a specific type of pack, they should be selected here.

8 Processing To include all examples of processing including primary processing, secondary processing, value added processing, fish preparation or any other activity where the product is changed (excluding activities undertaken by ‘10’ or ‘11’ below).

9 Contract processing

This refers to processing as above, but by companies that do not have ownership of the product.

10 Retail to consumer

This includes fresh fish counters at retailers, fish mongers, markets selling direct to consumers, etc. where the product will be taken away and prepared before being eaten by a consumer, or when sold in a traditional 'retail' environment.

11 Restaurant / take away to consumer

This includes any foodservice situation fish and chip shops, standard restaurants, quick service restaurants, etc. where the product is sold directly to consumers as 'ready to eat', or when sold in a traditional 'restaurant' environment.

12 Other Must be clearly defined and explained how it does not fit into another category


ANNEX B:

The screenshot below represents an example of how scope information is currently captured and displayed in the MSC’s eCert database.



ANNEX C:

Current uses of Scope information and issues raised

Below are the key users of scope initially identified. Further consultation with internal and external users of scope will continue to be carried out to better understand how scope data and the Find a Supplier tool are currently used and to highlight any potential considerations related to changing scope of certification. For example, over the next two months more analysis of the Supplier Directory through user-analytics and discussion with other MSC teams will take place.

Stakeholder Key uses of scope data Issues raised with current scope method Potential issues if scope method

changed (i.e. Option 1 or 2 adopted)

Chain of Custody Certificate Holders (CHs)

CHs use scope data through Supplier Directory in order to:

Find potential business partners.

Find new suppliers, and sources of MSC species, products and forms.

To check supplier’s Chain of Custody validity.

Initial feedback provided through direct discussion with and feedback from a limited number of CHs. Additional consultation is underway, and Google analytics and questionnaire on Find a Supplier site will be used to gather further information

Serves as a disincentive for companies to sell wider range of MSC products due to cost and time required to extend scope.

Supplier Directory is often not up-to-date or accurate with own or other’s details (limits usefulness and perceived value).

The fishery listed may not be accurate as supplier at next level up may change source fishery.

Species and Supplier details often change regularly.

Certificate Holders (CHs) often have extra species and fisheries listed on scope to reduce future updates – leads to inaccurate data.

Not all CHs are aware of scope requirements.

Source fishery often not listed.

Group managers are often required to update scope with a variety of clients and sites.

Activities recognised as important to scope, but not always for the supplier directory

Providing a more accurate and useable supplier database would add value for CHs and connect to new buyers

Being able to choose to have further information displayed publicly could be beneficial in generating new business.

CHs taking responsibility for updating products and species information perceived as manageable (further research needed)

Reliant on supplier/s (further up supply chain) providing accurate information

Potential new certificate holders

Scope data is used through the Find a Supplier Directory

Potential new CHs use this site to find potential suppliers or business partners

Used to justify value in gaining CoC

Google analytics and questionnaire on Find a Supplier site will be used to gather further information

To be determined





Certifiers/ Conformity Assessment Bodies (CABs)

Scope data is accessed mainly through the MSC’s eCert database and used for:

Audit preparation

Determining processes, and risks for audits

Understand client’s needs and activities

Update supplier lists in eCert.

To confirm species and product forms

For checking logo licenses

Difficult and time consuming to maintain

Unsure why product form and presentation is required

Administration cost required to update, and try not to pass this on to clients

Likely inaccuracies in scope data logged on eCert and Supplier Directory.

CHs often place extra data in Scope fields to “future proof” and avoid cost later, and to avoid being out of compliance

Possible to create duplicate entries

Groups and larger/ complex certificate holders create exponential growth in time/cost when updating scope

Scope doesn’t capture changes in non-MSC products (i.e. new risks can be introduced without certifier being alerted)

Current tool is generally cumbersome

Some field options are unclear/ duplicated e.g. “portions” and “steak portions”

Would like to see ecolabel licensing data captured in scope – so certifiers know whether to check this during an audit

Would like more efficient and clear process for managing scope data

Would be helpful to have subcontractors included in scope

Some elements of scope (io.e. activities and maybe species) are core to determining risk levels of client – other data, such as product form and storage, are less important

Could be useful to include product form purchased and sold (i.e. this company buys headed and gutted herring and sells fishcakes)

Some concern over how scope will be maintained if the certifier turns some of this responsibility over to companies

MSC Ecolabel Licensing team

Ecolabel product approval: License team uses scope data to check that products sent to MSCI are within the company’s scope, and are eligible to carry the MSC logo and claim.

Accuracy of scope data in eCert sometimes questionable

Limited ability to analyse, report on, and plan from the data, due to low trust in accuracy

Less certifier control would make it harder to trust/ identify errors in packaging

Fishery, species and Latin Name needed to be able to check packaging and claims

MSC Outreach teams

Scope data accessed through eCert and Find a Supplier site and used to:

Determine needs of potential/ current CHs

Enable linking of partners and CHs / suppliers

Ascertaining impacts of suspensions, withdrawals, gaps in supply chains (for example, alerting

Cost and time faced by certificate holders to keep scope up-to-date

CHs often place extra data in Scope fields to “future proof” and avoid cost later, and to avoid being out of compliance

Potential lack of understanding by certificate holders on the requirements.

Presentation field is often too

Any changes and developments could be in other languages

Increase in accuracy of supplier data would be positive

Ability to download data would be useful

Ability to search for multiple species, products etc. would be useful

Non-certificate holding organisations





downstream companies when a complicated.

Unable to break down data in to geographical regions

Full contact details are not always present or correct

Scope data does not make a clean distinction between types of companies or enable searching by type of company (i.e. restaurant/ trader/ broker/ processor etc.)

selling MSC product would like to be listed in supplier directory if possible

Important to maintain certifier control over ‘activity’ data

MSC Communications Team



Important to ensure the same accuracy and value for all users

Documents

MSC - Marine Stewardship Council Consultation … - Marine Stewardship Council Consultation Document: Scope of Certification Consultation Dates: 25th June – 10th August, 2012 MSC